AT&T's FCC Petition Should Be Denied: AT&T Should be Investigated

New Networks has filed comments with the FCC to deny AT&T's petition to close down the Public Switched Telephone Networks (PSTN), claiming it is too old and that it needs to be 'transitioned' to IP-based (using internet protocols) network. Instead, we request that the FCC immediately start investigating AT&T's business practices as well as the company's failure to supply material and essential facts about their deployment of U-Verse.

Read our Complete Comments, Backgrounder, the AT&T petition or others who have filed.

• FACT: AT&T's U-Verse service is a PSTN-based-copper-to-the-home service which relies on the aging, existing copper wires that currently go into customers' homes and offices and have been there for decades.
• FACT: AT&T has failed to disclose this material and essential fact in any state of federal proceeding we could find.
• FACT: Bait and Switch -- AT&T has been using deceptive materials claiming U-Verse is a fiber optic based service, without mentioning the role of the PSTN and this deception has been used to fool regulators, legislators, reporters and the public. Here is one of the many examples where AT&T does not mention that it is a PSTN-based-copper-to-the-home service and hypes the 'fiber optics'.

"AT&T U-verse® includes fiber optic technology and computer networking to bring you better digital TV, faster Internet, and a smarter phone.

• FACT: AT&T's U-verse over the PSTN already handles broadband, internet and VOIP as AT&T's "digital voice" is an IP-based phone service. Therefore, where is the transition? Where's the technical, regulatory or investment impediment?
• FACT: AT&T's current plan is based on the state-based American Legislative Exchange Council's (ALEC) model legislation that AT&T et al helped to create. AT&T, with Verizon and Centurylink, all ALEC members, have been able to get 23 states to remove some, if not all telecom regulations, and AT&T's August letter outlined the ALEC based -state plan.
• FACT: This entire plan is based on removing regulations and basic obligations like 'carrier of last resort', meaning the company no longer has to supply a working service (which includes both voice and data) to anyone in their 22 states.
• FACT: New Digital Dead Zones: AT&T and Verizon's plan is to abandon almost 50% of their customers and leave stranded businesses, schools, and residential customers' ability to use the networks for phone and data services. This includes basic services like fax, alarm circuits, or even ATM-cash machines, not to mention blocking competitors from using the networks.

• ? Is it OK to shut off grandma?
• ? Should small businesses lose their business services?
• ? Should rural customers be stranded in these new 'digital dead zones'?

• The "Wireless only" data doesn't include businesses or other services in the home like cable, broadband or internet.
• Watching "cable" services over wireless costs over750.00 a month as data caps block video usage.
• Reception and sound quality are just two problems with wireless in many areas of the US.

• FACT: There has been massive cross-subsidization of the companies' affiliates. Verizon has been able to not only dump expenses into the utilities, but it appears their 'affiliates' from the broadband, internet, long distance or even wireless are not paying their fair share back to the utility. This creates losses at the utility, which are then used as an excuse to go to the state commissions and get rate increases. When AT&T uses the PSTN wire for U-Verse, is the company reimbursing the utility to keep prices 'fair and reasonable' or are they manipulating the affiliate transactions?

• Report: "Verizon's State-Based Financial Issues & Tax Losses: The Destruction of America's Telecommunications Utilities, the Public Switched Telephone Networks (PSTN)."

Petition to Stop All PSTN 'Sunsetting' Proceedings:

We also filed a Petition in August 2012 to stop all PSTN proceedings because of financial conflicts of interest of its advisory board members and the manipulation of data to create faulty public policies.

• FACT; The majority of the FCC's Technical Advisory Council, (TAC) members have ethical and financial conflicts of interest as they have direct financial ties to AT&T or Verizon (who are also members.).
• FACT: Manipulation of Data: AT&T has submitted manipulated data about their "access line" accounting, which has been used by the TAC among others to help AT&T remove regulations. Its accounting doesn't include data lines including alarm circuits, special access lines, or PSTN-lines which now have VOIP over them. I.e.; U-Verse's voice service is NOT counted as a line, for example.
• FACT: The FCC, SEC, and the state Commissions have stopped requiring basic data about access lines, revenues or affiliate transactions.
  • The FCC stopped collecting (and available) basic data, "ARMIS", since 2007.
  • Verizon stopped publishing its state-based annual reports.
  • AT&T doesn't publish its state-based annual reports.
  • The state commissions are not collecting or auditing the data.